Anti-Money Laundering and Financial Crime Policy

1. Policy Statement & Commitment

[Paytali Technologies Ltd. / Operating Entity] ("Paytali") is firmly committed to preventing the use of its peer-to-peer currency exchange matching platform for money laundering, terrorist financing, proliferation financing, sanctions evasion, or any predicate financial crimes.

We adhere to international standards established by the Financial Action Task Force (FATF), as well as national AML/CFT legislation in our operating markets, including the Egyptian Anti-Money Laundering Law (Law No. 80 of 2002, amended by Law No. 78 of 2003 and subsequent executive regulations) and the Nigerian Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA).

2. Risk-Based Approach (RBA)

Paytali implements a Risk-Based Approach (RBA) to identify, assess, and mitigate financial crime risks. Under this framework:

• Every user and merchant is assigned an automated risk profile based on identity verification results, nationality, country of origin, volume velocity, and corridor risk;
• High-risk counterparties and cross-border transactions are subjected to Enhanced Due Diligence (EDD);
• Transaction velocity limits and monthly volume caps are automatically enforced based on the user's verified KYC tier;
• System rules flag rapid transaction splitting (smurfing or structuring) designed to evade reporting thresholds.

3. Customer Due Diligence (CDD) & Biometric KYC

No user may initiate or accept currency orders on Paytali without completing mandatory Customer Due Diligence (CDD). Verification is executed in partnership with Smile ID and encompasses:

• Validating government-issued identity documents against official national databases (e.g., Nigerian National Identity Management Commission [NIMC], Bank Verification Number [BVN], Egyptian civil registries);
• Real-time biometric facial recognition and active liveness verification;
• Verification of residential address and primary phone number via one-time SMS passwords (OTP);
• Cross-referencing verified names against designated commercial bank accounts to ensure zero third-party transfers.

4. Sanctions & Politically Exposed Persons (PEP) Screening

All users and merchants are screened prior to onboarding and re-screened on a continuous automated basis against global and local sanctions lists, including:

• United Nations Security Council Consolidated Sanctions List;
• United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List;
• European Union External Action Service Sanctions List;
• United Kingdom Office of Financial Sanctions Implementation (OFSI) List;
• Egyptian Money Laundering and Terrorist Financing Combating Unit (EMLCU) Watchlists;
• Nigerian Financial Intelligence Unit (NFIU) Sanctions Lists.

Any individual identified as a designated sanctions target is immediately blocked from the platform. Politically Exposed Persons (PEPs), their immediate family members, and close associates are subject to senior compliance officer sign-off and ongoing source-of-wealth scrutiny.

5. Transaction Monitoring & Suspicious Activity Reporting (SAR)

Paytali deploys automated behavioral monitoring algorithms and manual compliance auditing to detect anomalous transaction patterns, such as:

• Multiple rapid trades just below KYC tier step-up thresholds;
• Funds originating from high-risk commercial accounts or unverified third-party wallets;
• Abnormal velocity changes inconsistent with the user's declared economic profile;
• Orders involving accounts previously flagged for internet fraud, unauthorized card debits, or phishing scams.

Where reasonable suspicion of money laundering, terrorist financing, or predicate crime exists, Paytali compliance officers have a statutory legal duty to file a Suspicious Activity Report (SAR) / Suspicious Transaction Report (STR) with the Egyptian Money Laundering Combating Unit (EMLCU) or the Nigerian Financial Intelligence Unit (NFIU).

Statutory Anti-Tipping-Off Obligation: In accordance with international and domestic AML laws, Paytali is strictly prohibited from disclosing to any user or third party that a SAR or regulatory inquiry has been filed.

6. Record Retention

All Customer Due Diligence documents, identity records, biometric logs, order receipts, and transaction communications are retained securely for a statutory minimum period of five (5) years following the termination of the business relationship or completion of a trade.